A judge who has reason to believe that a motion for substitution was filed merely to delay or avoid a trial may deny the motion on those grounds note this post was based in part on information found in illinois pretrial practice by judge jennifer duncan brice james p flannery jr timothy w kelly kevin g owens james publishing 2005. Seven habits for effective law motion practice ntellectually challenging and emotionally stimulating motion practice is the most common courtroom experience in a legal services practice most civil actions involve several pre trial motions from seeking preliminary injunctive relief to requesting discovery sanctions and more civil . The determination of a forum non conveniens motion lies within the sound discretion of the trial court on review the trial courts decision will be reversed only if it can be shown that the court abused its discretion in balancing the relevant factors the plaintiffs right to choose the forum a plaintiffs right to select the forum . Looking forward parties in aia trial proceedings should develop strategies in view of the guidance provided in the practice guide update counsel should consider the impact of the availability of sur replies early rulings on motions to exclude and pre hearing conferences on trial strategy. Counsel should consider the impact of the availability of sur replies early rulings on motions to exclude and pre hearing conferences on trial strategy the practice guide update which contains
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